This case involves an appeal from the trial court’s order terminating the parental rights of the respondent mother for failing to rehabilitate. On appeal, the respondent mother alleged that the court-ordered specific steps placed unreasonable demands on her, causing her to feel overwhelmed, make poor decisions, and appear as though she was abdicating her parental responsibility. The appellate court affirmed the judgment of the trial court.

On September 13, 2005, DCF invoked a 96-hour hold on behalf of the three-month-old child, Cheila R., after her mother indicated that she was overwhelmed, depressed, and no longer desired to parent her daughter. The child was adjudicated neglected and committed to the department after a finding that the respondent mother had unresolved mental health and sexual victimization issues that negatively impacted her ability to parent.

On June 5, 2006, the respondent was placed at a maternity group home to facilitate reunification. On more than one occasion, the respondent requested that the child be returned to foster care to allow her off-site overnight visits with her boyfriend. She also violated the department’s service agreement by having her child ride in the maternal grandmother’s car, which lacked a child safety seat and had been totaled but never repaired. On September 29, 2006, the respondent requested that the child be placed in foster care. Over the next few months, the respondent failed to attend visits with her daughter and said that she was willing to consent to termination.

In affirming the judgment of the trial court, the appellate court agreed that the department had made reasonable efforts to reunify, but that the respondent mother had “not come to terms with her need for mental health treatment and education, in addition to gaining employment, housing and parenting skills that any parent must possess to protect and nurture a child.” The court agreed that termination was in the best interests of the child, who was not bonded to her mother and had thrived in a pre-adoptive foster home.